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The operations of Employment Fund are guided by Code of Conduct 

Employment Fund’s Board of Directors has approved the Fund’s Code of Conduct, which is updated on a regular basis. The purpose of responsible and ethical operations and the Code of Conduct that guides them is to help everyone in Employment Fund act correctly in all situations, even when there is no one present to witness it. The Code of Conduct aims to ensure and guide our operating culture to act transparently, honestly and as a unified team. Employment Fund’s internal instructions provide more detailed information on the subject areas.

You can read the different sections of the summary of the Code of Conduct for Fund employees below or open it in PDF via the link below.

Employment Fund’s main duties are based on the Act on the Financing  of Unemployment Benefits and the Government Decree on the Rules of Procedure of Employment Fund. Other legislation (e.g. Employment Contracts Act and the Act on Adult Education Benefits) also contains provisions on the Fund’s duties.

Employment Fund collects unemployment insurance contributions which are used e.g. to fund earnings-related unemployment security and to promote the development of employees’ competence through adult education benefits. Employment Fund is an important part of the Finnish social security system, and its customers are all employers that provide employment as well as employees aged 18–64 in Finland.

We operate in the administrative branch of the Ministry of Social Affairs and Health. Employment Fund is an independent institution managed by labour market parties and supervised by the Finnish Financial Supervisory Authority.

Our operations are based on our shared values.

In all our activities, we comply with national legislation, EU regulation and, where applicable, international legislation. Everyone working in the Fund must also follow our internal guidelines and participate in separately defined internal training. In addition to our general guidelines, please also familiarise yourself with the more detailed guidelines for your specific tasks.

We comply with the principles of good governance and openness in our operations. We ensure the equality and legal protection of our customers.

We contribute to preventing the grey economy. We comply with national and international sanctions regulations.

Each Fund employee is responsible to act correctly and to comply with laws, regulations and guidelines. Failure to comply with laws and regulations may have serious legal, financial and reputational consequences.

We do not accept bribery or corruption in any form whatsoever. We ensure that our activities are objective and transparent.

We do not request, accept, or give any gifts of more than minor value or hospitality that goes beyond reasonable limits. We never accept or offer any gifts or hospitality that could undermine public trust in us, our employees or our stakeholders, or damage the reputation of Employment Fund. It is prohibited to ask, accept or give any gifts or hospitality that could affect decision-making or appear to do so from a third-party perspective.

We exercise moderation in representing ourselves. We do not accept or offer gifts or hospitality repeatedly to the same persons or organisations. Any acceptable gifts or hospitality are given and received openly.

Participation in events organised and paid for by our stakeholders (hospitality) is acceptable if there is a genuine reason relevant to our operations for participation that is acceptable and documented. However, during an ongoing tendering process, we do not accept any hospitality, gifts or other benefits from a party that is or may be involved in the tendering process.

A conflict of interest refers to a situation in which there might be a conflict between personal direct or indirect interests and the interests of Employment Fund or our customers. The Fund follows the disqualification criteria defined for us, which allow us to avoid situations where conflict of interest may arise.

We comply with the disqualification provisions of the Administrative Procedure Act and Employment Fund’s guidelines on the circle of acquaintances and avoid dangerous work combinations. We do not participate in the processing or decision-making of matters that concern us of people close to us that could bring gain or loss to us or people close to us. We promote impartiality in all our tasks. We will disqualify ourselves from tasks where our disqualification is open to interpretation and an external examination could lead to a suspicion of the impartiality of Employment Fund.

We comply with Employment Fund’s own insider guidelines in both work tasks 
and personal securities trading

We comply with the provisions of the Act on Public Procurement and Concession Contracts and more detailed internal instructions concerning the Fund’s procurement.

We require our contractual partners to commit to our separate ethical principles for suppliers.

We pay particular attention to gift and hospitality guidelines in the procurement of Employment Fund. The parties involved in preparing the procurement, the parties sending and receiving the invitation to tender, the parties presenting the procurement and the parties making the decision on the procurement may not accept or offer any gifts or hospitality from a party that is or may be involved in the tendering process.

Employment Fund’s activities are governed by the Act on the Openness of Government Activities (‘Openness Act’) to the extent that Employment Fund exercises public authority.

Our documents are internal (intended for the Fund’s personnel) or public unless separate provisions have been laid down on the confidentiality of documents and information. However, it should be noted that in our operations, several documents and information are confidential under the Act on the Openness of Government Activities or special legislation. We also remember that the confidentiality obligation and prohibition of use continue after the termination of the employment relationship.

Everyone is responsible for ensuring the secrecy of information pertaining to the activities of Employment Fund. We process all data in accordance with the Act on the Openness of Government Activities, the Financing Act, data protection legislation and Employment Fund guidelines. Employees, elected officials or other stakeholders may not disclose personal data or any information related to the activities of Employment Fund without a legal right or obligation.

We understand that data protection is a fundamental right and everyone has the right to the protection of their personal data. We process personal data in accordance with legislation in a reasonable and transparent manner and with the legal basis laid down in the law. We only process the data to the extent and duration necessary for each purpose. We ensure the secure 
processing of personal data.

In addition to legislation, we comply with Employment Fund’s data protection principles and internal data protection guidelines.

With regard to information security, we strive to follow the industry-best practices and the principles of information security of Employment Fund.

Employment Fund owns the data contained by data resources produced as a result of its operations. We process and manage the data in our possession in an appropriate, reliable and responsible manner throughout the data life cycle.

In addition to legislation, we also comply with Employment Funds principles and guidelines of information management. On Employment Fund’s external website, we provide instructions on information requests under the Act on the Openness of Government Activities and the EU’s General Data Protection Regulation.

We use Employment Fund’s assets appropriately. We understand that the assets and rights of Employment Fund are intended for use by Employment Fund. In using and storing the assets of Employment Fund, we make sure that they will not get damaged or lost or end up in the possession of third parties. We protect the rights of Employment Fund and also respect the rights of others, and we do not allow the illegal use of other assets or rights in our activities.

We contribute to building a culture that takes everyone into account and value each other’s expertise. We comply with the principle of equal treatment in all employment relationships. We do not discriminate against anyone on the basis of age, origin, gender, nationality, language, religion, conviction, opinion, political activity, trade union activity, family relations, health, disability, sexual orientation or any other personal reason.

We do not accept inappropriate treatment, harassment or bullying in our work community.

We respect human rights as defined in the UN Declaration on Human Rights and workers’ rights as defined in the ILO Convention. We do not allow child labour or forced labour.

Employment Fund is a non-political organisation, i.e. we do not participate in or support political activities as an organisation. We provide information equally for the use of society and decision-makers from an implementation perspective.

The above does not restrict the freedom of expression or freedom of association of the elected representatives or employees of the Fund. However, we require caution on social media, for example. Any opinions must be presented clearly in the employee’s own name, and no internal or secret information pertaining to the Fund obtained at work may be used for personal purposes.

We want to act right and encourage everyone to raise questions and concerns. By preventing and responding to abuse, we provide Employment Fund with financial security, but also influence the reputation of Employment Fund and the trust of the personnel in Employment Fund as an employer. We take all violations, abuses and other inappropriate behaviour seriously.

Each Fund employee is obliged to report violations of the ethical guidelines, the Fund’s other guidelines or laws and regulations. Employees can submit reports with their name to their supervisor or management, or anonymously using the Fund’s whistleblowing system.

The whistleblowing system is also available through Employment Fund’s external website, which makes it possible to also report suspected abuses to stakeholders.

Code of Conduct for Supplier

Code of Conduct for Suppliers defines the minimum principles applicable to each product or service that a supplier must comply with when cooperating with the Employment Fund. These minimum principles are in line with the UN principles on business and human rights, the Global Compact principles and the principles of the ILO International Labour Organisation.

You can read the different sections of the Code of Conduct for Supplier below or download it via the link below.

Employment Fund’s duties are based on the Act on the Financing of Unemployment Benefits and the Government Decree on the Rules of Procedure of Employment Fund. Other legislation (e.g. Employment Contracts Act and the Act on Adult Education Benefits) also contains provisions on the Fund’s duties.

We collect unemployment insurance contributions which are used e.g. to fund most of the unemployment security, earnings-related pensions accumulated during unemployment security, pay security, and transition security for employees aged 55 or over. We also fund adult education allowances and scholarships for qualified employees. We grant adult education allowances until the end of 2025. Our clients are all employers that provide employment as well as employees aged 18-64 in Finland.

We operate in the administrative branch of the Ministry of Social Affairs and Health. Employment Fund is an independent fund managed by labour market parties and supervised by the Finnish Financial Supervisory Authority.

Our operations are based on our shared values:

  • Our customers come first
    We renew, we evolve, we act
    We are a united team.

This Code of Conduct for Suppliers defines the minimum principles that each supplier providing products or services to Employment Fund (hereinafter called “the Supplier”) must comply with when cooperating with Employment Fund.

These minimum principles are consistent with the UN Guiding Principles on Business and Human Rights, the Global Compact and the ILO Declaration on Fundamental Principles and Rights at Work.

Our Suppliers must undertake to comply with this Code of Conduct and ensure that the minimum principles set out in the Code of Conduct are met in their own actions and their supply chains.

In addition to legislation, the Supplier must comply with Employment Fund’s Code of Conduct for Suppliers when providing services, goods and solutions to Employment Fund.

The Supplier shall not directly or indirectly request or accept any payments or other compensations that could affect the supplier’s business decisions in a way not in keeping with honest practices in industrial or commercial matters.

The Supplier

  • undertakes to compete honestly and ethically.
  • ensures that confidential business information is kept confidential.
  • maintains accurate and appropriate information on their business operations in the registers of public authorities as required by legislation.
  • manages payments and other obligations relevant to their business activities appropriately throughout the supply chain.
  • does not accept corruption, including extortion and bribery. The Supplier does not offer, promise or give gifts that may result in dependency or expectation of returning the favour.
  • does not accept money laundering in any form.

The Supplier undertakes to contribute to preventing prohibited restrictions of competition and to support sustainable procurement in its supply chain.

Sustainable procurement means that the Supplier commits to carefully selecting its business partners, and identifying and preventing illegal business activities in their supply chain or risks related to violations of this Code of Conduct.

The Supplier ensures that the goods and services it sells have been produced in an environmentally responsible manner. The Supplier seeks to conduct environmental impact assessments covering the entire life cycle of goods and services and to set requirements for environmental friendliness and carbon footprint reduction also in its supply chain. Any generated waste is recycled and/or disposed of in a legal and responsible manner.

The Supplier is encouraged to use a certified environmental management system or a systematic environmental management scheme described in writing and to use and develop environmentally friendly solutions.

The Supplier undertakes to use and store carefully the property and information provided to it in the contractual relationship between Employment Fund and the Supplier.

The Supplier respects the immaterial property rights of Employment Fund and third parties and undertakes to protect Employment Fund’s confidential information from unauthorised use and publication.

The Supplier is obliged to respect human rights both in its own operations and in its supply chain and takes care of employee well-being. Through operational practices, and monitoring and steering mechanisms, the Supplier seeks to ensure that it is not involved, directly or indirectly, in human rights violations. The Supplier also requires the respect of human rights from companies belonging to its supply chain.

The Supplier

  • recognises the right of employees to organise, and their right to join or not to join organisations of their choice.
  • prohibits the use of child labour. If child labour is detected, the Supplier intervenes in the situation.
  • prohibits the use of forced labour. Forced labour can be identified using ILO indicators of forced labour.
  • treats employees with dignity and respect and prohibits all forms of discrimination against employees.
  • supports the acceptance of diversity and equal opportunities for employees.
  • prohibits and seeks to prevent intimidation and harassment of employees.
  • provides terms of employment in a language that the employees understand.
  • pays for normal working hours and overtime at least the applicable minimum wages in accordance with national laws or general industry practice.
  • complies with the legislation applicable to working hours.

The work environment must be healthy and safe for employees. This means that, at the workplace, employees are not exposed to conditions that may pose a risk to their physical or mental health.

The purpose of the transparency of the supply chain is to ensure compliance with the obligations imposed by this Code of Conduct. The Supplier and/or its parent company shall publish a free-form responsibility report on an annual basis.

To monitor compliance with the obligations, Employment Fund may require the supplier to present reports and documents, to correct observed shortcomings and to present a report on the completion of corrective measures. Employment Fund may audit the supplier and/or its subcontractors in accordance with the terms of the procurement contract.

Any activities in violation of this Code of Conduct for Suppliers may be reported to Employment Fund as follows:

Whistleblowing system 

The whistleblowing channel is the Employment Fund’s confidential reporting channel. It is of the utmost importance for the Employment Fund to respond to any suspected or alleged misconduct. By preventing and responding to misconduct, we not only provide the Employment Fund with financial security but also influence the reputation of the Employment Fund as well as the trust of the personnel and other stakeholders. 

The Employment Fund’s employees and other stakeholders can both use the whistleblowing channel. The whistleblowing channel can be used to report any information or justifiable suspicions of which the whistleblower has become aware in conjunction with their work, task or job regarding matters specified in the Whistleblower Act or violations of the Employment Fund’s ethical guidelines or suspected breach of the rules and regulations of the financial market.  

Reports in accordance with the Whistleblower Act (in Finnish) may, for example, concern issues such as: 

  • public procurement,  
  • financial services, products and market, 
  • preventing money laundering and terrorism financing, 
  • product safety and compliance, 
  • environmental protection, 
  • public health, 
  • consumer protection, 
  • protection of privacy and personal data, 
  • security of network and information systems. 

In HR-related matters (such as harassment, discrimination, occupational safety or workplace atmosphere), the primary communication channel is the Employment Fund’s HR department. In this case, the current labour laws and other applicable laws shall apply. 

Misconduct may result in consequences for the Employment Fund and its employees, investors, customers, other stakeholders or individuals. 

Although you do not need to have proof to support your suspicions, you should submit your report in good faith. 

A report can be submitted without concrete evidence or absolute certainty of whether an offence has taken place or not. The whistleblower may have either knowledge or a justified suspicion of the occurrence of an offence. You can submit a report here

In order to ensure anonymity, the whistleblowing system is administered by our third-party partner, WhistleB (Whistleblowing Centre). The whistleblowing procedure is encrypted and password-protected. All reports are processed in strict confidence and in compliance with confidentiality provisions. 

All reports submitted via the whistleblowing system are processed by a separate report processing team established by Employment Fund. On a case-by-case basis, it may be necessary to use specific other experts to investigate a matter. Both members of the processing team and any experts assisting with the investigation of the case must be familiar with the general principles of disqualification and recuse themselves from processing an individual report if its content is linked to the person processing the report for work-related reasons. Periodically, statistical data regarding the number and nature of reports received is also reported to governing bodies. 

An acknowledgement of receipt is issued to the whistleblower within seven days of the receipt of the report through the whistleblowing system and the further measures pursuant to the specified report processing procedure are taken to verify the validity of the report and, if necessary, intervene. Once the investigation is complete, or at the latest within three months of issuing the acknowledgement of receipt, the whistleblower will be notified of the measures taken on the basis of the report. 

The personal data and other information of whistleblowers or other parties concerned is processed in compliance with legislation valid at the time of processing as well as our data protection policy. 

For detailed information on personal data processing, see ourdata protection notice. 

Please note that the system is not intended for customer feedback. You can submit customer feedback using ourgeneral contact information.  

Employment Fund’s whistleblowing system is the primary channel for reporting suspected offences.  You can submit a report here

Suspected misconduct may be reported through the centralised external reporting channel of the Office of the Chancellor of Justice provided that the matter is subject to the scope of the Whistleblower Act and 

  • the whistleblower has reason to believe that measures have not been taken within the given period of time or the breach cannot be effectively handled on the basis of an internal report, or 
  • the whistleblower has justified reason to believe that they are at risk of countermeasures as a result of the report. 

For more information on whistleblowing, see the Office of the Chancellor of Justice website. 

Page updated: 29/12/2025